Battery passport for importers

Of all the affected roles, the importer's is the most uncomfortable. You carry full responsibility for data created in a plant you do not own, in a country whose authorities have no interest in the EU Battery Regulation.

The obligation attaches to placing the battery on the EU market for the first time. If you import, you are the one who owes the passport. Pointing to the manufacturer in China or Korea does not relieve you of it.

What that means in practice

Without a valid battery passport, the goods may not be placed on the market from 18 February 2027. They then sit in the warehouse, paid for but unsellable.

On customs: the implementing regulation provides that customs authorities can check electronically whether an imported product has a validly registered passport. Technically this is not yet sharp, because the link between the registry and the EU customs single window CERTEX only has to be established within four years of entry into force. So no automatic check happens at the border for now.

Do not rely on that. The substantive obligation applies in full from the cut-off date, and market surveillance authorities check independently of customs.

Your real problem is not the obligations

What you need is known. What is missing is the data.

The manufacturer sends you a data sheet. It states the capacity, the cell chemistry, perhaps a certificate. What it does not state: a carbon footprint calculated according to the EU methodology, evidenced recycled content shares for lithium, cobalt and nickel, the exact material composition, chain of custody for critical raw materials, dismantling information for recyclers.

At the manufacturer, this information frequently does not exist in the required form at all. So it is not a matter of requesting it, but of getting the manufacturer to produce it. That is a procurement topic, not an IT topic.

Three things that help now

Ask early, in writing and structured. An unspecific request for “sustainability data” will be politely ignored. A concrete field list with a deadline gets answers. That is exactly what our supplier portal is built for: the manufacturer fills in a structured form in their own language, without an IT project arising on their side.

Pull passport readiness into purchasing. Your most effective leverage is order volume. Put the data delivery into the next framework agreement, while you are still negotiating rather than asking. Anyone who first raises it in January 2027 is no longer negotiating.

Plan for supplier changes. In many import structures the plants change from batch to batch. You need a mapping between shipment, plant and the individual battery shipped, otherwise the passport cannot be evidenced.

Where the manufacturer plays along

A manufacturer established outside the EU can appoint an authorised representative in the Union to take on certain obligations. If your supplier has an interest in an orderly EU presence, it is worth raising this option. Check case by case which obligations actually transfer and which stay with you as the importer, and have that confirmed legally.

In the majority of cases it stays true that you have to sort it out yourself.

Timeline

Now to October 2026: Delimit the affected articles, send a structured data request to all relevant manufacturers, take the data delivery into ongoing negotiations.

October to December 2026: Complete verification as an economic operator in the EU DPP registry, set up the data model, check incoming supplier data and follow up.

January 2027: Test operation, settle the marking of the goods, align the process with your forwarder and customs agents.

The lead time here is longer than in other segments, because every follow-up question runs across a time zone and frequently across a language barrier. Budget for at least two to three iterations with each manufacturer.

Frequently asked questions

The manufacturer is in China. Are they not responsible? Not for the EU market. Whoever places the battery on the EU market for the first time carries the manufacturer obligations. That is you.

What happens if the manufacturer does not supply the data? Then you cannot place the affected goods on the market from the cut-off date. That is why the data delivery belongs in the supply contract and not in an email request.

Can we outsource the registration in the EU registry? Yes, the registration activities can be delegated to a third party. The legal responsibility stays with you. Details on our EU DPP registry page.

Will customs check this from February 2027? The legal basis exists, but the technical link to CERTEX is still being built. The obligation itself applies in full regardless.